Provision
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Effective date
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Recordkeeping status
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Qualified disaster recovery distributions
Section 331 (optional)
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Effective for disasters occuring on or after January 26, 2021
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Ready to support
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Employer Roth contribution option
Section 604 (optional)
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Effective for contributions made after December 29, 2022
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Intend to support in late 2025
We’re evaluating solutions based on IRS guidance.
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Terminal illness early distribution penalty tax exception
Section 326 (optional)
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Distributions made after December 29, 2022
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Ready to support
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Option to reduce notices to unenrolled employees
Section 320 (optional)
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Plan years beginning after December 31, 2022
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In progress
We plan on developing a new notice template to assist plan sponsors in preparing the required participant notification for those who decide to take advantage of this change. We expect to update our automated notice delivery process by June 30, 2025, to incorporate this notice type.
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Relaxed required minimum distribution (RMD) rules ― age and penalty adjustments
Section 107 (mandatory)
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Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022
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Ready to support
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Self-certification for hardship withdrawals
Section 312 (optional)
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Plan years beginning in 2023
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Intend to support in 2025
We’re developing a solution to accommodate plans that decide to offer self-certification hardship withdrawals. More information will be communicated on this process in the near future.
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Emergency Roth savings accounts
Section 127 (optional)
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Plan years beginning after December 31, 2023
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Evaluating
We’re monitoring the demand for in-plan emergency savings accounts. Our early research and surveys indicate that there is not a high level of interest.
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Hardship distribution change for 403(b) plans
Section 602 (optional)
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Plan years beginning after December 31, 2023
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Ready to support
We support hardship distributions from earnings on elective deferrals and from qualified non-elective contributions and qualified matching contributions, as well as earnings from these sources.
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Higher dollar limit for mandatory distributions
Section 304 (optional)
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Distributions made after December 31, 2023
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Ready to support |
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Domestic abuse distributions
Section 314 (optional)
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Distributions made after December 31, 2023
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Ready to support
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Distributions for certain emergency expenses
Section 115 (optional)
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Distributions made after December 31, 2023
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Intend to support in late 2025
We’re evaluating solutions based on IRS guidance.
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RMD treatment of Roth amounts ― Roth balance exclusion
Section 325 (mandatory)
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Taxable years beginning after December 31, 2023, but not to distributions which are required with respect to years beginning before January 1, 2024, but are permitted to be paid after such date
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Ready to support
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Student loan payments as elective deferrals
Section 110 (optional)
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Plan years beginning after December 31, 2023
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Under evaluation
We’re evaluating what’s needed to facilitate student loan matching. Our existing functionality allows plan sponsors to remit matching contributions when they independently verify that student loan payments have been made.
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Required automatic enrollment and auto escalation
Section 101 (mandatory)
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Plan years beginning after December 31, 2024
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Ready to support
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Wider plan eligibility for part-time workers
Section 125 (mandatory)
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Plan years beginning after December 31, 2024
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Ready to support
Note: This provision doesn’t supersede SECURE 1.0’s eligibility rules for 401(k) plans, so workers may qualify for plan eligibility under the three-year rule as soon as 2024 or the two-year rule in 2025.
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Higher catch-up contribution limit for ages
60 to 63
Section 109 (optional)
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Plan years beginning after December 31, 2024
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Ready to support
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Required Roth catch-up contributions for high-income earners
Section 603 (mandatory)
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Taxable years beginning after 2025
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Ready to support
IRS guidance has delayed this requirement from 2024 to 2026. If your plan allows catch-up but not Roth contributions, we encourage you to add Roth contributions now and ensure that your payroll vendor is prepared for the change.
Starting in 2026, we’ll offer warnings during payroll processing for participants age 50+ who are high earners and approaching the 402(g) contribution limit.
We plan to have the ability to recharacterize pre-tax deferrals to Roth to further support this provision.
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